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ARTICLE · 03 SEPTEMBER 2025

CSA's Chargeback Ban Proposal: A Quick Reminder Before Comments Close

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In June 2025, the Canadian Securities Administrators (CSA) released proposed amendments to National Instrument 31-103 – Registration Requirements, Exemptions and Ongoing Registrant Obligations...

CanadaFinance and Banking
Onyi Ubah
Onyi Ubah
Garth J. Foster
Garth J. Foster
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In June 2025, the Canadian Securities Administrators (CSA) released proposed amendments to National Instrument 31-103 – Registration Requirements, Exemptions and Ongoing Registrant Obligations that will prohibit the use of "chargebacks" in the distribution of public investment fund securities. If this flew under your radar as the summer got underway, you're not alone. There is, however, still time to engage: the public comment period runs until September 24, 2025.

What Are Chargebacks?

In the context of the CSA's proposal, chargebacks refer to compensation arrangements where a dealing representative is paid an upfront commission when a client purchases investment fund securities. The representative is later required to repay some or all of that commission if the client redeems the securities early, typically within a pre-defined "chargeback period". This period is agreed to by the firm of the dealing representative and the investment fund manager of the fund or

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